There are a lot of books – and consultants – offering advice on improving safety culture.  “Safety culture” even has its own Wikipedia entry.  Many of these resources do not; however, spend much time discussing trust.

If trust is critical to OH&S performance, what is it and how do you get it?

Although I usually refer to www.dictionary.com for my definitions, in this case I prefer the definition Steven Covey gives in his book – Nothing is as Fast as the Speed of Trust.  He defines trust as confidence and he defines distrust as suspicion.  He then goes on to discuss why trust is important – to individuals and society – and how to develop personal trustworthiness as well as trust in relationships and organizations.

In his chapter on organizational trust, Steven Covey sets out four questions to ask to determine whether your organization has a high-trust environment.

• Does your organization have integrity – a culture of honesty and ethical behavior?
• Does your organization have good intent – a culture of caring?
• Does your organization have the right people to deliver value?
• Does your organization deliver on its promises?

Want to improve your OH&S performance?

Consider how you can use your OH&S management system to build or support trust rather than tear it down.

© ENLAR® Compliance Services, Inc. (2009)

In this paper, the authors sought to answer the following question –

Do management-based OH&S initiatives work?

This is an excellent article.  It is well-researched, well-written and, most importantly, actually supported by independent research.

It also challenged my beliefs about the effectiveness of management system standards.  That was uncomfortable, to say the least.

This paper concludes with the following paragraph:

These findings have important implications for regulatory theory, and suggest that the claim that management based regulation – or meta-regulation more broadly – can overcome many of the traditional challenges of regulating complex organizations is overstated….in [the mining] industry at least, management based regulation is substantially constrained by low organizational trust, minimal mine site commitment and divided loyalties.

The research for this paper was conducted in the mining industry – the Australian mining industry to be exact.  The report consists of two case studies that were developed based on reviewing OH&S documentation and conducting interviews at 13 mine sites.  The sites selected were within the two very different mining organizations and included both facilities characterized as “leading” and “laggard” based on their reported injury statistics.

Based on their research, the authors concluded that trust is more important in achieving good OHS outcomes then corporate management system standards.  They argue that although corporate standards may be outwardly complied with – employees go through the motions – an OHS management system will not be effective in an atmosphere of mistrust.  As the paper points out “the gap between corporate rules “in the books” and “in action” was often a chasm.”

Does this mean we should throw out our management system standards?

I don’t think so – nor did the authors of the paper.

What this paper does provide is a “caution sign” that makes common sense.  Management systems must be supported by a culture of trust if they are going to be fully effective.

© ENLAR® Compliance Services, Inc. (2009)

• The occupational health and safety (OH&S) consequences of their work activities and behaviors
• Their roles and responsibilities for following OH&S policies and procedures
• The consequences of not following these policies and procedures

As anyone who has put together communication and training programs will tell you, trying to raise awareness can be a difficult undertaking.

Therefore, I was struck by an article in the August 2009 ABA Journal that discussed how a New York City ordinance for “raising awareness” to prevent obesity ended up the subject of a lawsuit.

In response to a report that showed that more than half of New York City adults were overweight, New York put in place a health code ordinance that required chain restaurants to post the calorie counts of the foods they served on menus and menu boards.  The New York State Restaurant Association sued to block this ordinance, claiming it either violated the restaurants rights to free speech or was preempted by federal law.  In early 2009, the 2^nd Circuit Court of Appeals rejected both arguments.

What I found particularly interesting about this article was the discussion of the results of customer surveys that were conducted both before and after the legislation went into effect of individuals leaving fast-food restaurants. 

Prior to posting the information on menus, only 23% of the people surveyed said they saw calorie information.  This information was available on posters, food packaging and websites – but not on the menu.  Afterward, 60% of those surveyed reported seeing the calorie information. More importantly, one in four of those who noticed the information said it affected their purchases.

What is the lesson for OH&S management systems?

Programs to increase awareness can impact individual behavior; however, the awareness information must be provided in a way and at a time that it can be used effectively.

OH&S “awareness” information should not be buried in safety procedures, on web sites or in training materials. It needs to be made available when the associated work activities are actually being performed –

• Embed it in your work instructions
• Include it in forms that need to be completed anyway
• Post it on signs in appropriate areas

If the information is important, make it available when it counts.

© ENLAR^® Compliance Services, Inc. (2009)

There are those that argue that safety – like quality – is free (in line with the classic book by Philip Crosby – Quality is Free).  The premise being that, in the long run, effective safety programs save money and add business value.  Unfortunately, this premise is difficult to prove.  This argument strikes me as similar to the “free market” argument that financial markets don’t need to be regulated because they will regulate themselves.  Perhaps that is true in textbooks, but rarely – if ever – in practice.

OHSAS 18001 specifically requires that top management determine the need for and ensure the availability of the resources essential to maintain the established OH&S management system and prevent workplace injuries and ill health (Section 4.4.1 of OHSAS 18002).

In this context, providing the ”essential” OH&S resources is not simply a matter of money.  Top management also needs to determine that there is sufficient staffing with the necessary competency and skills (i.e. the necessary human resources).  In additional, top management needs to ensure that the required organizational infrastructure and technology resources are in place to ensure that the OHSMS is implemented and maintained.

Besides the obvious “lack of money” problem that plagues many OHS programs, there are other resource issues that commonly arise in occupational health and safety management systems -

• Lack of human resources – Even if an organization has sufficient OH&S funding, it is not uncommon to find organizational staffing models and hiring freezes in place that limit the availability of the “person-hours” available to less than that which is really needed to complete the tasks required.
• Obsolete technology, particularly software – It is not uncommon for funding – as well as IT support – to be nonexistent for maintaining the specialized software solutions that were put in place when the OHS programs were initially established.  As a result, the software soon becomes a hindrance to performance rather than an effective management system tool. 
• Lack of PMs – In many cases, significant money is spent to put controls in place (e.g. machine guarding) but there is no funding allocated for the ongoing inspection and maintenance of these controls to ensure that they continue to be effective in addressing OHS hazards and risks.

Only if top management is involved in ensuring that resources are specifically allocated to OH&S, will your OHSMS be successful.

 © ENLAR^® Compliance Services, Inc. (2009)

The first was a press release from the American Society of Safety Engineers (ASSE) in which the President of ASSE applauded the apparent drop in workplace injuries and illnesses recently reported by the US Bureau of Labor Statistics.  According to the preliminary BLS report, the overall rate of both fatal and non-fatal work injuries in the United States dropped in 2006.  Acccording to the BLS press release, there were 153 fatalities from expsoure to harmful substances or environments for all US workplaces in 2006.

The second was a news report from the Indian Express entitled “Ticket to Hell” that reported that 227 sanitary workers employed by the Pune Municipal Corporation died in just the last 30 months.  This news report goes on to ask: ”[I]sn’t it incredible that an occupation as horrifying as cleaning the sewers of the city in the most primitive fashion possible should need a newspaper report to ensure something as basic as protective gear and health insurance for those who risk limb and lung every minute of their working life?”

© ENLAR^® Compliance Services, Inc. (2007)

According to reports in The New York Times and Forbes, two firefighters were killed in a fire and two were injured in a separate construction accident last week at the Deutsche Bank building near Ground Zero.  This building has been empty, and undergoing demolition, since it was damaged during the 9/11 terrorist attack six years ago.

These incidents highlight the importance of having a functioning OH&S management system – even for construction and demolition projects.

What were the obvious management system failures?

• Lack of appropriate risk assessment / inspection processes.  Apparently, the fire department was not inspecting the building because of concerns about exposure to toxic materials.
• Lack of emergency preparedness procedures.  No plans were in place for fighting a fire in the building.
• Failure to take effective corrective and preventive actions.  This demolition project had apparently been plagued by accidents and the primary contractor has been cited for dozens of safety violations.

According to The New York Times article, Scott Stinger, the Manhattan Borough president, summed up the situation as follows:

“[W]e sent 100 firefighters in with little water, not enough oxygen and no plan….They have got to shut this down pending a safety review.  I don’t understand why that is so difficult.”

It’s too bad a “safety review” wasn’t done before more people died.  Even better – make sure an effective OH&S management system is put in place.

© ENLAR^® Compliance Services, Inc. (2007)

Therefore, my interest was peaked by an article I read today in the June 25, 2007, issue of InformationWeek entitled Beyond E-Mail.

This article discusses Procter & Gamble’s efforts to improve employee collaboration.

What did the CEO of Proctor & Gamble describe as the biggest barrier to collaboration?

E-mail.

Why?

The sender of an e-mail controls the agenda.

What is P&G promoting to replace e-mail?

Blogs.

OH&S Professionals take note.  Blogging is likely to be in our future.

© ENLAR^® Compliance Services, Inc. (2007)